Appeal of Paducah & Illinois Railroad

*1005OPINION.

James:

The taxpayer alleges error on the part of the Commissioner, first, on the ground that the amounts above set forth were *1006contributed by the railroad companies as capital to the taxpayer and did not constitute income; and, second, that the taxpayer is a mere joint facility and agency of the railroad companies, and as such is not a separate entity which can be the receiver of income or taxable under the revenue laws. On the latter point we do not agree with the contention of the taxpayer, and must hold that it is a separate taxable entity, distinct from the railroad companies,…